In response to climate change, governments are developing policies to move toward ultra-low-energy or ‘zero-energy’ buildings (ZEBs). Policies, codes, and governance structures vary among regions, and there is no universally accepted definition of a ZEB. These variables make it difficult, for countries such as China that wish to set similar goals, to determine an optimum approach. This paper reviews ZEBs policies, programmes, and governance approaches in two jurisdictions that are leading ZEBs development: Denmark and the state of California in the United States. Different modes of governance (hierarchy: principal–agent relations, market: self organizing and network: independent actors) are examined specifically in relation to policy instruments (prescriptive, performance or outcome-based). The analysis highlights differences in institutional conditions and examines available data on energy performance resulting from a building policy framework. The purpose is to identify ZEBs governance and implementation deficits in China and analyse alternative governance approaches that could be employed in China, which is currently developing ZEBs targets and policies. Conclusions suggest that the ZEBs governance structure in China could benefit from widened participation by all societal actors involved in achieving ZEBs targets. China's ZEBs policies would benefit from employing a more balanced hybrid governance approach.